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Sticky subject of labelling

The European Commission is proposing to ‘recalibrate’ its popular energy labelling scheme and put an end to the days of A+ and A+++. But the heating and cooling industry has concerns, as Andrew Gaved reports

The cooling and heating industries in Europe have come together in a rare alliance with their compadres in the lighting sector to voice their concerns over the European Commission’s  (EC) proposal to ‘recalibrate’ its decade-old energy labelling scheme.

Rather than improve consumer-driven energy efficiency, which is the EC’s intention, these groups suggest that it could actually be fostering confusion with its policy.

On the face of it, the Commission’s intentions seem honourable enough:  the scheme, whereby all sorts of energy-using products, from refrigerators to TVs (and, from next year, boilers too) have been given an A-G rating, has been hugely popular with consumers as a way of comparing energy efficiency.

But the fact that the scale has been largely unchanged for 10 years, while technology has improved means that nearly all the D-G ratings are now redundant.

In fact, some categories, the EC notes, are only rated A and above, making it something of a nonsense as a ‘benchmark’.

On top of that, since the last recalibration in 2010, which introduced the concept of A+ and above, for the most efficient equipment, there has been such a proliferation of pluses – reaching A+++ in some product categories – that the ratings have becoming unwieldy and confusing.


As the EC says, it has effectively become a victim of its own success: “Such a positive result now makes it difficult for consumers to distinguish the best performing products: they might think that in buying an A+ class product they are buying one of the most efficient on the market, while in fact they are sometimes buying one of the least efficient.”

So the EC proposal is to revert to a single scheme, with the scale returned to the original ‘A’ to ‘G’ rating. This, the Commission believes, will theoretically make it easier for the consumer to compare products’ energy outputs.

But the cooling and heating industries are concerned that the Commission has not thought the consequences through.

The combined might of the European Heating Industry (EHI), refrigeration and air conditioning body, the European Partnership for Energy and Environment (EPEE), and lighting association Lighting Europe have warned that this recalibration may have completely the opposite effect on consumers than intended.

The associations are concerned that if a product is suddenly re-rated from an A down to an E, or as they deem it ‘downgraded’, then the consumer risks being put off purchasing it altogether.

The groups set out their worries in a joint statement: “We fully support the EC’s goal of increasing energy efficiency in Europe by encouraging consumers to make more energy-efficient purchase choices.

However, we caution that the proposed new energy labelling regulation unveiled today could have, in a number of cases, the opposite effect by slowing down the uptake of energy efficient appliances.

For new space and water heaters, which are the products with the highest potential for energy saving, the proposal will downgrade technologies from, say, class ‘A’ to class ‘E’ on the energy label.

And this would be the case also for other extremely efficient appliances, such as LED lamps and LED lighting systems. But who would invest in an ‘E-class’ product? This technology downgrading, coupled with the complexity of the revision process, would create confusion and make Europe waste precious time in its quest to reduce energy consumption by 2030.”

The three bodies accept that some categories do need a revision such as domestic refrigerators, where they say “the energy label top classes are getting saturated due to technological development and innovation”, but they say creating a single scheme is a blunt instrument, intended to solve a problem that exists with only a few products.

They say: “A problem for one or two products should not prevent a well-designed system from unleashing its potential for energy efficiency. The current framework legislation already offers a solution for that: changing the product-specific regulations.”

Andrea Voigt, director general of EPEE, added: “The review of the Energy Labelling Directive could prove to be counter-productive by confusing consumers and creating more red tape. In line with the Better Regulation principle, we call on decision-makers to preserve the effectiveness of the Energy Label by ensuring it helps consumers choose energy-efficient products and provides incentives for industry to invest in those products.”

Federica Sabbati, secretary general of the EHI, said: “Europe should not miss its energy efficiency target.

The potential for energy saving in the heating sector is huge, as space and water heating account for 85 per cent of the energy consumption in a building. The label should help modernise the inefficient stock by fostering the market uptake of extremely efficient technologies.”

In all the furore over A-G ratings, though, the second part of the EC announcement is in danger of getting overlooked – and this one has the potential to really make a difference to the supply industry.

This is the proposal to institute a central database for all products, whereby all manufacturers and importers will be required to upload all their product labelling details.

While it is currently a legal obligation to label all energy-using products, it will not come as a surprise to the cooling industry to learn that some European manufacturers simply ignore their responsibilities.

Increased sales

The EC estimates that between 10 per cent and a frankly eye-watering 25 per cent of products do not currently comply with the labelling regulations. Such non-compliance brings an estimated energy penalty to the European region of around 10 per cent, the Commission says.

Requiring the details to be entered onto the database will help the enforcing authorities in each country to work out who is complying, it says, without the usual rigmarole of demanding the information from each individual supplier.

For its part, the Commission sees an opportunity to further drive energy efficiency with this recalibration proposal, and in the process, it believes, to bring manufacturers around €10bn a year in increased sales from less confusing labelling.

Of course in addition, it believes there will be significant energy savings accruing, as consumers choose what is actually the most efficient product, rather than what seems to be.

In fact it estimates that the revision of the A-G rating will provide savings equivalent to the annual energy consumption of the Baltic countries combined (17 million tonnes of oil equivalent).

Quite how it arrived at such a figure from what is effectively an administrative change is not very clear however.

With figures like that, it is hard to see how the Commission will be dissuaded from its labelling crusade. So, the cooling and heating industries have a fight with the regulators on their hands.

It is a situation with which the sector has become all too familiar in recent years.

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